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Packaging Act

VerpackG is the German packaging law, replacing VerpackV, the previous German packaging regulation. VerpackG is suitable for all manufacturers, importers, distributors and online retailers who sell goods on the German market. All companies selling goods in Germany must prepare solutions to arrange packaging recycling after use to continue trading in the country.
German new packaging law VerpackG mandates manufacturers and sellers to sell products containing packaging for the first time, including outer packaging, final retail packaging, disposable containers / containers used in the catering industry, and shipping packaging materials. Declare the packaging materials, type and weight for sale.

Who is affected by the German Packaging Act?

The packaging law demands a recycling fee for all packaging which typically ends up in consumer or household waste. This means that any B2C products are affected while in some cases it includes B2B sales as well, for instance when selling to small companies, hotels, or restaurants – where packaging usually ends up in the same waste stream. 

Extended producer responsibility generally affects the company which fills empty packaging with goods, or which puts packaged products on the market for the first time. Thus, the following parties are responsible for paying recycling fees:

  • Those who import products from abroad and sell them within Germany

  • Those who manufacture products in Germany or have them manufactured under their own brand

  • Those who sell products and ad additional packaging (e.g. shipping box in e-commerce)

  • Foreign companies selling directly to German consumers (cross-border b2c e-commerce)

What are possible consequences of non-compliance?

Pursuant to VerpackG §34, failing to comply with these obligations can result in fines of up to 200,000 EUR. 

Moreover, the LUCID Packaging Register is visible to the public and any competitor can easily identify if a company is registered or not. In the latter case, German law allows competitors to send a cease and desist letter which can be very costly for the recipient.

This is common practice and the main reason why following the German Packaging Act is so important even for small businesses. 

Registration in the LUCID Packaging
Register (ZSVR)

You can access the LUCID Packaging Register  The registration process is easy to understand and free of charge. It should be completed before placing the first products on the market. If you have not done it yet, you should not lose time.

Obtaining a Packaging License

Besides registering with the LUCID Packaging Register, you need to obtain a Packaging License to comply with the law. 

To buy a packaging license, you first need to calculate your annual packaging quantities. How many kilograms of paper, plastics, glass, etc. will your business accumulate this year? This determines the price of the license – typically a few cents per kilogram waste.

You can only license your packaging with a German Dual System (authorized recycling system). 

An easy way to get the best price on your packaging license is to contact a our IGM expert team that specializes in packaging compliance. 

What We Can Do for You
  • Assistance with the registration/licencing of each individual manufacturer 

  • Participation in approved dual system by using negotiated special conditions by bundling quantities and taking over services

  • Reporting all quantities for packaging, electronics and batteries in Germany and the whole EU, all in one online portal

  • Comprehensive advice for the classification of packaging, recyclable packaging, declaration of completeness, etc.

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